APRIL 2014
SPECIAL EDUCATION CLUSTER:
84.027
84.173
SPECIAL EDUCATION – GRANTS TO STATES
SPECIAL EDUCATION – PRESCHOOL GRANTS
State Project/Program:
IDEA, Part B (619) Preschool (PRC 049)
IDEA, Part B (611) (PRC 060)
Coordinated Early Intervening Services (PRC 070)
Risk Pool (PRC 114)
Special Needs Targeted Assistance (PRC 118)
Preschool Targeted Assistance (PRC 119)
Federal Authorization:
U.S. Department of Education
1. Individuals with Disabilities Education Act (IDEA), Part B as amended,
Sections 611-619, and 20 U.S.C. 1411-1420
N. C. Department Of Public Instruction
Agency Contact Person
Address Confirmation Letters To
Gene Bruton, Accountant
Program
N.C. Department of Public Instruction
Valerie Herndon, IDEA-Part B Consultant (PRC 060, 070 & 118)
Division of School Business
Exceptional Children Division
Monitoring and Compliance Section
Valerie.herndon@dpi.nc.gov (919) 807-3996
Education Building
6334 Mail Service Center
Vivian James, Preschool Consultant (PRC 049 & PRC 119)
Raleigh, NC 27699-6334
Exceptional Children Division
(919) 807-3726
Vivian.james@dpi.nc.gov (919) 218-8384
Tracy Riddle, Consultant (PRC 114)
Exceptional Children Division
Tracy.riddle@dpi.nc.gov (919) 807-3995
Ira Wolfe, Section Chief (student record review/audit exception)
Exceptional Children Division
Ira.wolfe@dpi.nc.gov (919) 807-3976
Financial
Gene Bruton, Accountant
Monitoring and Compliance
Gene.bruton@dpi.nc.gov (919) 807-3726
The auditor should not consider the Supplement to be “safe harbor” for identifying audit
procedures to apply in a particular engagement, but the auditor should be prepared to justify
departures from the suggested procedures. The auditor can consider the supplement a “safe
harbor” for identification of compliance requirements to be tested if the auditor performs
reasonable procedures to ensure that the requirements in the Supplement are current. The grantor
agency may elect to review audit working papers to determine that audit tests are adequate.
I. PROGRAM OBJECTIVES
In 1975, Congress passed P. L. 94-142, the Education for All Handicapped Children Act, which said
that all students with disabilities are entitled to a Free Appropriate Public Education (FAPE). The
Education for All Handicapped Children Act has been reauthorized six times since its inception, in
1983, 1986, 1990, 1992, 1997 and most recently 2004. However, the responsibility of states to ensure
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FAPE by monitoring/auditing the provision of special education and related services in local
education agencies has not changed. The Exceptional Children Division of the NC Department of
Public Instruction (DPI) believes that monitoring contributes to the development of quality programs
for students with disabilities in North Carolina, assures appropriate use of categorical funds, and
assists school systems in documenting accountability. Most importantly, monitoring protects the
rights of children, parents, and the school system. Since February 2000, the focus of monitoring
activities conducted by the Exceptional Children Division has been through the Continuous
Improvement and Focused Monitoring System. In the North Carolina monitoring system, local
education agencies (LEAs) include city, county school districts, charter schools and state-operated
programs.
The purposes of the Individuals with Disabilities Education Act as amended in 2004 (IDEA, Part B) are
to: (1) ensure that all children with disabilities have available to them a free appropriate public
education which emphasizes special education and related services designed to meet their unique needs;
(2) ensure that the rights of children with disabilities and their parents are protected; (3) assist States,
localities, educational service agencies and Federal agencies to provide for the education of all children
with disabilities; and (4) assess and ensure the effectiveness of efforts to educate children with
disabilities (Section 601(d) of P. L. 108-446).
IDEA also includes specific provisions for parentally-placed private school children with disabilities.
LEAs are required to the extent consistent with the number and location of children with disabilities
who are enrolled by their parents in private, including religious, elementary and secondary schools
located in the school district served by the LEA, to make available the provision for participation in the
Part B program. A proportionate share of IDEA, Part B funds must be reserved each fiscal year for the
provision of services. (34 CFR §300.130-144)
In addition, IDEA was amended to allow and sometimes require LEAs, including charter schools and
state-operated programs, to use funds provided under Part B for Coordinated Early Intervening Services
(CEIS). This provision, which is found in section 613 (f) of the IDEA (20 U.S.C. §1413(f)) and the
regulations in 34 CFR §300.226 permits LEAs to use Part B funds to develop and provide CEIS for
students who are currently NOT identified as needing special education. The IDEA and its
implementing regulations permit LEAs to use not more than 15 percent of the amount the LEA receives
under Part B of the IDEA, less any amount reduced by the LEA pursuant to 34 CFR §300.205
(adjustments to local fiscal efforts), to develop and implement CEIS. Under 34 CFR §300.646(b)(2), if
a State identifies Significant Disproportionality based on race or ethnicity in an LEA, with respect to
the identification of children as children with disabilities, the identification of children in specific
disability categories, the placement of children with disabilities in particular educational settings, or the
taking of disciplinary actions, the LEA MUST use the maximum amount (15 percent) of funds
allowable for CEIS. (34 CFR §300.205, 208, 226 and 646)
The objectives of the IDEA, Part B Special Education Grants to States are as follows:
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
Section 611: To provide grants to States, and through the state education
agency (SEA) to LEAs, to assist in - (1) providing a free appropriate public education to all
children with disabilities through the provision of special education and relates services for
children ages three through 21.(IDEA, Part B, Section 611(a)(1))

Section 619: To provide grants to States to assist in making available special
education and related services for children with disabilities ages three through five. (IDEA,
Part B, Section 619(a))
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
Risk Pool: To assist LEAs in addressing the needs of high need children with disabilities
ages three through 21. (IDEA, Part B, Section 611(e)(3))

Coordinated Early Intervening Services: To assist LEAs in developing services to - (a)
reduce academic and behavioral problems for students in kindergarten through grade 12 at
risk of placement in special education; (b) ensure students are appropriately referred to
special education; and (c) comprehensively serve children, particularly, but not exclusively,
in those significantly overidentified racial or ethnic groups. (IDEA, Part B, Section 613(f);
71 FR 46626-46627)

Special Needs Targeted Assistance: To assist LEAs in specific areas of local need including
the establishment and coordination of reading/writing coordinators and training; math
coordinators and training; early literacy activities; Positive Behavior Intervention and Support
coordinators and training; Responsiveness to Instruction coordinators and training; related
services support; autism and low incidence support and training; and transition training.
(IDEA, Part B, Section 611(C)

Preschool Targeted Assistance: To assist LEAs in specific areas of need including
professional development and support around activities to improve Child Find programs,
early childhood transitions, early childhood outcomes, and improving preschool least
restrictive environment (LRE) opportunities for handicapped preschoolers. (IDEA, Part B,
Section 619(e)(f))
II. PROGRAM PROCEDURES
In North Carolina, IDEA, Part B (611) Grant funds are used by LEAs to initiate, expand and continue
provisions of special education and related services to children with disabilities ages three through 21.
Children with disabilities who reach the age of 22 during the school year can complete that school
year. Children with a developmental delay disability are children ages through seven or prior to
entering third grade, whichever comes first.
IDEA, Part B (611) Grant funds are also used by LEAs to provide services for eligible parentallyplaced private school children with disabilities. The formula for calculating the LEA proportionate
share amount is included in the local grant. LEAs must ensure the required amount is reserved and is
available as needed for services to eligible children. The proportionate share is calculated each fiscal
year and has a carryover period of one additional year.
Additionally, IDEA, Part B (611) Grant funds are used by LEAs to provide CEIS for students in
kindergarten through grade 12 currently not identified as needing special education. Annually, data is
analyzed by the State Education Agency for all LEAs, including charter schools and state-operated
programs, to determine if they have Significant Disproportionality. If an LEA has Significant
Disproportionality, they are mandated to use 15 percent of their IDEA allocation (PRC 049 and 060)
for CEIS. LEAs that do not have Significant Disproportionality may choose (permissive users) to use
up to and including 15 percent of their IDEA allocation (PRC 049 and 060) for CEIS. For LEAs
mandated to provide CEIS, 15 percent of their IDEA allocation is calculated and transferred from
PRC 060 to PRC 070. Funds must remain (27 months) in PRC 070 for CEIS. LEAs that are
“permissive users”, submit a form designating the amount of funds (not to exceed 15 percent of their
IDEA allocation) to be transferred from PRC 060 to PRC 070. Prior to January 14 during that fiscal
year, an LEA can request in writing that all or a portion of available funds be transferred back to PRC
060 from PRC 070.
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IDEA, Part B (619) Grant funds are used to initiate or expand special education and related services
to children with disabilities who are 3, 4, and those 5 year-old children who are not eligible for public
kindergarten.
Funds are distributed according to the cash request procedures discussed in the DPI Cross-Cutting
Requirements, DPI-0.
The amount of funds that the SEA, the DPI, distributes to each LEA is based upon the following:
IDEA, Part B (611) (PRC 060)
Base payments: Each LEA shall receive a base amount equal to a proportional share of 75% of
the FY 1999-2000 IDEA Title VI-B grant. The LEA’s portion is calculated based on the
December 1998 child count.
Base payment adjustments for any fiscal year after the base year fiscal year are adjusted:
1. If a new LEA or Charter School is created, the LEA’s base allocation shall be divided among
the new LEA or Charter School and affected LEA based on the relative numbers of children
with disabilities ages 3 through 21 contained in the most current December 1st child count.
2. If one or more LEA is combined into a single new LEA, the base allocations of the merged
LEAs shall be combined.
3. If the LEA’s geographic boundaries or administrative responsibility for providing services to
children with disabilities ages 3 through 21 is changed, the base allocations of affected LEAs
shall be redistributed among affected LEA. It will then be based on the relative numbers of
children with disabilities ages 3 through 21 contained in the most current December 1st child
count.
Funds remaining after distribution of the base shall be allocated as follows:
1. Eighty-five percent (85%) of remaining funds shall be allotted to those agencies on the basis
of ADM of children enrolled in public and private elementary and secondary schools within
each agency’s jurisdiction.
2. Fifteen percent (15%) of remaining funds shall be allotted to those agencies in accordance
with their relative numbers of children living in poverty, as determined by the December 1st
free lunch count.
Coordinated Early Intervening Services (CEIS) (PRC 070)
The formula for mandated CEIS is 15% of the LEA’s total IDEA, Part B annual allocation
(611and 619). The formula for permissive CEIS is up to and including 15% of the LEA’s total
IDEA, Part B annual allocation (611 and 619).
IDEA, Part B (619) Preschool (PRC 049)
Base payments: Each LEA shall receive a base amount equal to a proportional share of 75% of
the FY 1997-98 IDEA Title VI-B Preschool grant. The LEA’s portion is calculated based on the
December 1996 child count.
Base payment adjustments for any fiscal year after the base year fiscal year:
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1. If a new LEA or Charter School is created, the LEA’s base allocation shall be divided among
the new LEA or Charter School and the affected LEA based on the relative numbers of
children with disabilities ages 3 through 5 contained in the most current December 1st child
count.
2. If one or more LEAs are combined into a single new LEA, the base allocations of the merged
LEAs shall be combined.
3. If two or more LEAs with geographical boundaries or administrative responsibilities for
providing services to children ages 3 through 5 change, the base allocations of the affected
LEAs shall be redistributed among affected LEAs. This redistribution is based on the relative
numbers of children with disabilities ages 3 through 5 contained in the most current
December 1st child count.
Funds remaining after distribution of the base shall be allocated as follows:
1. Eighty-five percent (85%) of remaining funds shall be allotted to those agencies on the basis
of ADM of children enrolled in public and private elementary and secondary schools within
each agency’s jurisdiction.
2. Fifteen percent (15%) of remaining funds shall be allotted to those agencies in accordance
with their relative numbers of children living in poverty, as determined by the December 1st
free lunch count.
Risk Pool (PRC 114)
The Risk Pool allocation is based on an approved budget submitted by the LEA. Per child
allotments (state aid and federal 611) are subtracted from the costs of special education and related
services on an approved application. The remaining funds are allocated to the LEA/Charter School.
Funds are child specific and all unused funds must be returned.
Special Needs Targeted Assistance (PRC 118)
The Targeted Assistance allocations are provided to support implementation of research-based
initiatives administered by the Exceptional Children Division. The amount allocated varies from
LEA and is dependent about which initiatives are implemented. Examples of initiatives include:
Positive Behavior Intervention and Support (PBIS), reading, math, autism problem-solving teams,
intensive behavior support transition, and related services support.
Preschool Targeted Assistance (PRC 119)
The Targeted Assistance allocations are provided to support implementation of research-based
initiatives administered by the Office of Early Learning and are specific to children with disabilities
ages 3-5 years. The amount allocated varies from LEA and is dependent about which initiatives are
implemented. Examples of initiatives include: play-based assessment teams, Child Find support,
and Center for Social and Emotional Foundations for Early Learning (CSEFEL).
III. COMPLIANCE REQUIREMENTS
The NC Department of Public Instruction (DPI) mandates that all testing in the DPI Cross-Cutting
Requirements be performed by the local auditor. Please refer to Cross-Cutting Requirements DPI-0.
Other procedures that pertain to this program can be found in the US Department of Education CrossCutting Section and the Federal Compliance Supplement.
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A. Activities Allowed or Unallowed
Compliance Requirement – Funds may be used by an LEA only in accordance with State and
Federal laws, regulations and policies, and only for those services or activities included in its
project application for grant funds. (34 CFR 300.200)
Audit Objective – To determine that expenditures are allowable and are properly recorded.
Suggested Audit Procedures:
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Obtain a copy of the Budget Balance Reconciliation Report (305/705) from the finance
officer and compare to local accounting records for conformity.
Obtain a copy of the 611 and 619 project plans from the local program coordinator and
review expenditures to determine that expenditures are in accordance with the project
plans.
Review the 611 and 619 Project/Budget Narrative Section, “Use of Funds”/”Use of
Project Funds & Budget”. Compare this section with actual budget to determine funds
are used as indicated in approved grant.
Review salary expenditures to determine that personnel paid from these funds do not
exceed budgeted personnel in approved program budget, and CEIS plan budget for
services restricted to non-identified students.
Obtain a copy of the approved Risk Pool application(s) (student name removed) and
review expenditures to determine that expenditures are in accordance with the approved
application(s).
Obtain a copy of the approved CEIS plan in the 611 grant application from the local
program coordinator to determine if CEIS is addressed. Review expenditures to
determine that expenditures are in accordance with the CEIS plan.
Review expenditures for Targeted Assistance (PRC 118, 119) and related documents to
determine that expenditures are recorded for initiatives administered by the Exceptional
Children Division.
Obtain a list of student records, list of professional personnel (i.e. teachers, related
service provider) and December 1 child count roster from the Central Office, Exceptional
Children Program. Conduct record review test to determine that funds are used in
accordance with state policies and federal regulations.
Review the following records: Parental Permission (Consent) to Place; most recent
Individualized Education Program (IEP); and IEP that was in effect on December 1 of the
child count year being audited.
Compare student records to December 1 child count roster. Audit exception (return of
funds) occurs if:
o IEP not in effect on child count date.
o Missing documentation on child count date: (a) IEP and/or (b) Parental
Permission (Consent) for Placement.
o Inability to document appropriate committee participation at time of initial or
reevaluation eligibility/placement determination.
o Misclassification – incorrect identification of the child count roster (this roster
does not match the placement decision and/or the IEP).
o LEA is unable to locate student record/folder.
Compare personnel list to teacher/service provider of student record and
related payroll expenditure reports to determine if funds expended are used for personnel
found to have expired licenses or are teaching out of field.
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Funds will be required to be reimbursed to the appropriate program report code (PRC) if the
funds were expended in a manner in conflict with federal and/or state laws, regulations, policies
and procedures.
Compliance Requirement - An LEA may use Federal funds only for the excess costs of
providing special education and related services to children with disabilities. Special education
includes specially designed instruction, at no cost to the parent, to meet the unique needs of
children with disabilities, including classroom instruction, instruction in hospitals and institutions,
instruction in physical education (special physical education, adapted physical education,
movement education, motor development), home instruction, and instruction in other settings.
Special education includes speech-language pathology services, travel training and vocational
education if the services otherwise meet the requirements above. Related services include
transportation and such other supportive, developmental and corrective services as are required to
assist a child with a disability to benefit from special education, including speech-language
pathology and audiology services; orientation and mobility services; psychological services;
physical and occupational therapy; recreation including therapeutic recreation; school social work
services; interpreting services; early identification and assessment of disabilities in children;
medical services for diagnostic or evaluation purposes; school health and school nurse services;
parent counseling and training; and counseling services, including rehabilitation counseling (34
CFR 300.202(a)(2), 300.39)
In general, an LEA meets the excess cost requirement if it has spent at least the minimum average
amount of funds spent on all children for the education of its children with disabilities before
funds under IDEA, Part B are used. This amount must be calculated annually to prove that the
minimum average amount of funds spent on all children was expended for the fiscal year. (34
CFR 300.202(b)(2), 300.16)
Audit Objective – To determine that Special Education Federal funds are used only for the
excess costs of providing special education and related services to children with disabilities.
Suggested Audit Procedures:


Test expenditures and related records to determine if funds were used for special education
costs and related services, as listed above.
Review the sub-recipient’s calculation of the minimum average amount of funds spent on
all children and the amount of funds spent on children with disabilities on the Excess Cost
Computation Form. Verify that at least the minimum average amount of funds spent on all
children was spent on children with disabilities before IDEA, Part B funds were expended.
Compliance Requirement - LEAs must reserve a required proportionate share amount for
parentally-placed private school children and account for expenditures. (34 CFR 300.130-144)
Audit Objective – To determine that required IDEA, Part B (611) federal funds are reserved and
expenditures are allowable and recorded.
Suggested Audit Procedures:


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Test expenditures and related records to determine if funds were used for parentally-placed
private school children.
Review and evaluate procedures for recording expenditure of proportionate share funds.
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
Obtain copy of IDEA, Part B (611) project plan – Project Participant Chart/Nonprofit
Parentally-Placed Private School Children and Project Narrative/Private School
Participation/Parentally-Placed. Compare the calculated proportionate share amount with
expenditures and the narrative plan to determine funds were used for allowable activities.
B. Allowable Costs/Cost Principles
Addressed in the NC Department of Public Instruction Cross-Cutting Requirements.
C. Cash Management
Addressed in the NC Department of Public Instruction Cross-Cutting Requirements.
E. Eligibility
Compliance Requirement - Only students who have been evaluated and determined as having
autism, intellectual disability, hearing impairment, speech or language impairment, visual
impairment (including blindness), serious emotional disability, deafness, orthopedic impairment,
other health impairment, specific learning disability, deaf-blind, developmental delay (ages three
through seven), traumatic brain injury or multiple disabilities, and who, by reason of the
disability, need special education and related services are eligible for participation in this
program. (34 CFR 300.8, 300.133-134, 300.301, 300.306, 300.311, 300.641, 300.645, 300.646)
Audit Objective – To determine that IDEA, Part B funds were used only for the education of
children with disabilities.
Suggested Audit Procedures:
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Review and evaluate procedures for providing an accurate count of eligible participants,
including parentally-placed private school children.
Review records on the number of disabled children served to determine if the number of
disabled children reported by the LEA is adequately supported.
Determine whether IDEA, Part B funds were used to pay for services to children who are
ineligible to participate in the program. If IDEA, Part B funds were used for such children,
ascertain the amount of those funds so used.
Review procedures for determining participant eligibility and ascertain if they conform to
the preceding criteria.
Review records and procedures to determine that Preschool Targeted Assistance
expenditures are only for students with disabilities ages 3-5.
Eligibility for Sub recipients – The Department of Public Instruction program administrators
determine if the eligibility requirements are met when the project and budget are approved.
Compliance Requirement - Only students in kindergarten through grade 12 (with a particular
emphasis in kindergarten through grade 3) who are NOT currently identified as needing special
education or related services, but who need additional academic and behavioral support to
succeed in a general education environment are permitted to use IDEA, Part B funds for CEIS.
Funds for CEIS may be used for professional development activities for the deliverance of
scientifically based academic and behavioral interventions, including scientifically based literacy
instruction, and where application, instruction on use of adaptive and instructional software; and
activities that provide educational and behavioral evaluations, services, and supports. Also, CEIS
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funds may be used to carryout services aligned with activities funded by and carried out under the
ESEA, but are to supplement, not supplant funds made available under the ESEA for those
activities. (34 CFR 300.208, 300.226, 300.646; Section 613(f)(5))
Audit Objective – To determine that IDEA, Part B CEIS (PRC 070) funds were used only for the
education of children not identified as having a disability and enrolled in grades
kindergarten through grade 12.
Suggested Audit Procedures:
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Review CEIS plan (within 611 project application) and evaluate procedures for providing
services only for eligible participants (K-12 students NOT currently receiving special
education/related services).
Review documentation of the number of non-disabled children receiving CEIS to
determine if the number of children reported by the LEA in the CEIS section of their 611
project application is adequately supported.
Determine whether IDEA, Part B CEIS (PRC 070) funds were used to pay for services to
children who are identified as needing special education/related services. If IDEA, Part
B CEIS (PRC 070) funds were used for such children, ascertain the amount of those
funds so used.
Eligibility for Sub recipients – The Department of Public Instruction program administrators
determine if the eligibility requirements are met when the project and budget are approved.
F. Equipment and Real Property Management
Addressed in the NC Department of Public Instruction Cross-Cutting Requirements.
G. Matching, Level of Effort, Earmarking
1. Matching - This compliance requirement does not apply at the local level. No testing is
required.
2. Level of Effort - Addressed in the Federal Compliance Supplement.
Compliance Requirement – LEAs must not reduce the level of expenditures for the education of
children with disabilities made from local or state and local funds below the level of those
expenditures for the preceding fiscal year. (34 CFR 300.203) The DPI Maintenance of Fiscal
Effort (MOE) Calculation Form must be completed annually and the expenditures reported in the
IDEA, Part B (611) Grant by September 30 to document state and local expenditures. If the First
Preceding Fiscal Year MOE is less than the Second Preceding Fiscal Year MOE, the LEA must
complete the DPI Justification Form for documentation of reduction due to allowable exception
(34 CFR §300.204) or adjustment (34 CFR §300.205; Appendix D).
Audit Objective – To determine that the LEA MOE is accurate and that the calculation of state
and local funds expended for the education of children with disabilities for both the first and
second preceding years are correct.
Suggested Audit Procedures:

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Review the DPI MOE Calculation worksheet and determine accuracy of reported state
and local expenditures for FYs 2012-13 and 2011-12.
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For the designated MOE figure, if the First Preceding Fiscal Year amount is less than the
Second Preceding Fiscal Year amount as documented on the Calculation worksheet,
review the Justification Form (that should accompany the worksheet) and related
documents to verify the reduction.
If “adjustment” to local MOE was used and MOE was reduced, determine if the amount
of funds expended by the LEA for CEIS (PRC 070) counted toward the maximum
amount of expenditures that the LEA could reduce the local MOE.
3. Earmarking - This compliance requirement does not apply at the local level. No testing is
required.
H. Period of Availability of Federal Funds
Addressed in the US Department of Education Cross-Cutting Section.
Compliance Requirement - Expenditures may not be incurred before the project/plan begins on
July 1 of each fiscal year. Any expenditure prior to the beginning date is considered unallowable
and must be refunded to DPI.
Audit Objective – To determine that no expenditures were incurred prior to the date the project
began.
Suggested Audit Procedures:

Review transactions to verify that no expenditures were incurred prior to the approved
application beginning date.
I. Procurement and Suspension and Debarment
Addressed in the NC Department of Public Instruction Cross-Cutting Requirements.
L. Reporting
Addressed in the US Department of Education Cross-Cutting Section, NC Department of Public
Instruction Cross-Cutting Requirements and the Federal Compliance Supplement.
M. Sub recipient Monitoring
This compliance requirement does not apply at the local level. No testing is required.
N. Special Tests and Provisions
Addressed in the US Department of Education Cross-Cutting Section, in the Federal Compliance
Supplement, and in the NC Department of Public Instruction Cross-Cutting Requirements.
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